On behalf of Avera McKennan, a Catholic Health System in eastern South Dakota and the surronding stages, I appreciate the opportunity to comment on the CMS Implementation Guide for Quality Reporting Document Architecture Category I and Category III.

On pg. 11 of the DRAFT CMS implementation guide for Quality Reporting Document Architecture Category I and Category III part f., the statement says, “This patient shall contain exactly one [1..1] ethnicGroupcode, which SHALL be selected from ValueSet Ethnicity Value 2.16.840.1.114222.4.11.837 DYNAMIC.”

The value set 2.16.840.1.114222.4.11.837 gives two choices, which includes patients who select Hispanic or Latino OR patients who select Not Hispanic or Latino. The value set should also include patients that have declined to give their ethnicity. Because this value shall contain exactly one [1..1], our health system feels that there should be a decline option available for patients who prefer not to give their ethnicity when seen.

On pg. 23 under 8.1.2 author, more clarification on what this section means would be appreciated. Is patient while scheduling the appointment? In many clinics, one provider might be scheduled to see a patient but a different physician actually sees the patient. In that instance, the signing provider or the billing provider should receive credit and not the provider who was initially scheduled with the patient.